1 Answer
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No. The first is a comma splice. Both I can no longer remember her face and too much time has passed are independent clauses. They should be separated by a colon, semicolon or period, or linked by a conjunction. An excellent choice for this example is for:

I can no longer remember her face, for too much time has passed.

The second example is grammatically correct, as both independent clauses are aptly separated by a semicolon:

I can no longer remember her face; too much time has passed.

Here is the Strunk & White (Elements of Style) reference:

Do not join independent clauses by a comma.

If two or more clauses, grammatically complete and not joined by a conjunction, are to form a single compound sentence, the proper mark of punctuation is a semicolon.